12 December, 2012 Katrin Heinze, Bundesbank CEN/WS XBRL CWA1: European Filing Rules CWA1Page 1

Objectives Standardisation of the European XBRL architecture and common instance filing rules to cover appropriately the list of harmonisation topics listed in Annex B of the CEN WS XBRL Business Plan Facilitate transparency on the harmonised reporting data across Europe increase interoperability between services and applications overcome lack of harmonisation in the use of the XBRL standards reduce the reporting burden of international acting reporting entities by providing the possiblity to standardize the reporting processes Definition of an European Data Point Methodology to represent the requirements of European reporting frameworks in a data model link the business requirements with the technical transfer format create a human readable representation of the content and relations defined in XBRL Page 2CWA1

Level of Harmonisation in Europe Page 3 European Supervisor Reporting entity Data Point Model ? © cundus AG XBRL Data Format & XBRL Filing European Reporting Frameworks Harmonised Not harmonised

Deliverables of CWA1 Official CEN Deliverables Specification documentEuropean XBRL Architecture Specification documentEuropean Filing Rule set Non-normative documentEuropean Data Point Methodology Complementary deliverables (depending on time constraints) Definition of Best Practices on Tagging of cells Versioning of European taxonomies Dealing with European taxonomy extensions Conformance Suite on taxonomy syntax rules CWA1Page 4

Organisation of CWA1 team work Regular conference calls via powwownow.compowwownow.com Cooperation on documents via Wiki technology Regular CEN WS XBRL F2F meetings Page 5CWA1

Filing rules as first deliverable of CWA1 Background for the definition of filing rules XBRL is a framework for the definition of data formats provides a high degree of flexibility for the creation of taxonomies and instance documents flexibility requires complex IT systems to react appropriately on all possible variants that the standard allows, like definition of units, accuracy of values, usage of footnotes, periods, identifiers etc. Page 6

European Filing Rules (EFR) Rules to be followed for the preparation and validation of instance documents in an European filing process Place additional constraints on XBRL instance document Advantages Harmonization on a technical level Enhance the interoperability of IT systems Ease of comparison of reporting data Ease the validation of instance documents Giving rules to reporting entities as guidance Harmonized rules decrease the reporting burden for reporting entities across Europe Codified rules can be automatically tested currently only with proprietary software Page 7 ? XBRL Filing

Related approaches ApproachYearStatusPublisherCoverageRules on FRIS PWD 2 XII 3 XBRL onlyXBRL Instances Global Filing Manual 2010Best Practices SEC, FSA Japan, IFRSXBRL StandardXBRL Instances and Taxonomies European Filing Rules 2013PWD 2 CENXBRL StandardXBRL Instances Page 8 1Financial Reporting Instance Standards 2Public Working Draft 3XBRL International Inc. European Filing Rules: part of the CWA1 deliverables of the standardization process of CEN/WS XBRL De-jure standard by 2014 oriented to reporting entities preparing the filings on basis of EIOPA and EBA taxonomies Recommendations to be adopted by NSAs and European Supervisory Authorities FRIS GFM EFL

Structure of the Deliverable Currently 45 rules separated in two chapters Filing syntax rules Rules for the complete document to be filed Instance syntax rules Syntax rules for the instance document and its subordinated objects Contexts Facts Units Footnotes Open discussions (small selection) How to ensure validity according to XBRL Formula in huge instance files? Should it be allowed to send partial datasets? Should XML fragments in scenario be prohibited? How to define the language, accept multiple languages in one instance? Page 9

Modeling aspects for standardization Filing rules need to be implemented on sender and receiver side to ensure that the requirements of the filings are met FRIS and GFM define rules in natural language exclusively  possible ambiguities while interpreting the rules Rules must be easily understandable by software developers Way forward by using modeling techniques for the defined constraints Current rules are based on texts and represent an informal model Formal models limit the margin of interpretation for persons with mathematical background Formal models are based on an appropriate meta model which provide formal syntax and semantic Aim: Rules should be covered to a high degree in a formal model Page 10

Modeling the European Filing Rules Object system comprises the clearly delimited real system and also its relevant environment. The object system is the XBRL instance document and the constraints defined on the preparation of XBRL instance documents. The constraints are based on the objects contained in an instance document and the relations among each other. Meta model provides model components, rules on how to combine components and the meaning (semantic) for the components and relations. UML class diagram to describe the structure of the XBRL instance by showing the classes, their attributes and possible methods. OCL (Object Constraint Language) is a formal language for specifications, which refers to an UML model to describe constraints about the objects in the model. Model system must be consistent and complete. It must reflect the structure of the object system. Page 11 Object system Model system Meta model modeling

Draft model system for EFR Page 12

Collaborative work progresses in XBRL Wiki Page 13

How to contribute Take part in the discussions on XBRL Wiki Login request via Via Google group CEN-WS-XBRL-CWA1 Page 14 discussion

Next steps Non-normative document on European Data Point Model Identification of its characteristics Describe its objects and their relations Define rules to be followed for Creating data formats Ease the understanding for business experts Supporting the implementation of interfaces Combining related reporting frameworks Creating data structures to be used in data warehouses Creation of a formal model to ease the implementation Page 15 Data Point Model

Thanks for your attention Page 16 Comments or questions? CWA1